종합소득세 경정청구 거부처분 취소청구의 소
The appeal is dismissed.
The costs of appeal are assessed against the Plaintiff.
The grounds of appeal are examined.
1. Wage and salary income under Article 20(1) of the former Income Tax Act (amended by Act No. 14389, Dec. 20, 2016) includes not only all economic benefits in relation to the provision of labor by nature, regardless of the form of payment or title, but also benefits closely related to the provision of labor on the premise of labor (see, e.g., Supreme Court Decision 2007Du1941, Oct. 25, 2007). Meanwhile, in order to ensure that income subject to taxation is realized, even if it is not necessary until the income is realized, the right to generate income should be considerably mature and confirmed in light of the feasibility of the realization thereof, and therefore, it is merely established without this degree. Whether the right to generate income is mature or finalized shall be determined by comprehensively taking into account the nature of each individual right and the contents of the legal and factual relations, and in particular, if there is no dispute between the recipient and the beneficiary regarding the existence and scope of the claim.
(See Supreme Court Decision 96Nu2200 delivered on April 8, 1997, etc.). 2. Review of the reasoning of the lower judgment and the record reveals the following facts. A.
Around June 2005, the Plaintiff was enrolled in G Co., Ltd., and was enrolled in B Co., Ltd. (hereinafter “B”) on July 1, 2006 and was appointed as a director on April 13, 2007.
At the time of work B, the Plaintiff was in charge of the authorization and permission related to the C business approval, and after the approval of the business, D.